1. May 12, 2009 Annual EPA QA Conference San Antonio, Texas LEADING CHANGE Kenna Yarbrough USEPA/NEIC Denver, CO (303) 462-9256 yarbrough.kenna@epa.gov ELEVATING ENVIRONMENTAL FIELD SAMPLING AND MEASUREMENT ACTIVITIES TO A HIGHER LEVEL

2. Leading Change……. Presentation Overview 3 rd Party Accreditation 3 rd Party Accreditation Advanced/Alternate Concepts for Field Environmental Programs Advanced/Alternate Concepts for Field Environmental Programs Other Program Advancement Options Other Program Advancement Options 1 2 3

3. 3 rd Party Accreditation For Field Activities Based on ISO Standard 17025 - General Competence In Carrying Out Tests Based on ISO Standard 17025 - General Competence In Carrying Out Tests ( or ISO Standard 17020 - General Criteria for the Operation of Various Types of Bodies Performing Inspection) Similar to ISO 9000 – Quality Std. but Adds Competence Similar to ISO 9000 – Quality Std. but Adds Competence 1

4. Accreditation at NEIC (and Region 4 SESD) Accrediting body: Forensic Quality Services (www.forquality.org) Accrediting body: Forensic Quality Services (www.forquality.org) Encompasses: Encompasses: –Environmental measurement activities –Forensic activities Incorporates EPA Quality Manual and ASCLD/LAB* aspects Incorporates EPA Quality Manual and ASCLD/LAB* aspects NEIC also has NVLAP** accreditation for bulk asbestos determinations NEIC also has NVLAP** accreditation for bulk asbestos determinations * American Society of Crime Laboratory Directors/Laboratory Accreditation Board [www.ascld.org] * * National Voluntary Laboratory Accreditation Program

5. Accredited Environmental Measurements Laboratory Measurements Laboratory Measurements Field Sampling Field Sampling Field Measurement and Monitoring Field Measurement and Monitoring

6. Breakdown of Accredited Field Sampling Activities (Scope) Wastewater Wastewater Water Water –Surface Water –Groundwater Asbestos Asbestos Surface (Wipe) Surface (Wipe) Soil Soil Container and Tank Container and Tank Air Air * Photos from EPA Office of the Administrator (Multi-media Operations and Services – MOSS) – Eric Vance photographer

7. Breakdown of Accredited Field Measurement and Monitoring Activities (Scope) LDAR Monitoring LDAR Monitoring Site Safety Monitoring and Screening Site Safety Monitoring and Screening General Physical Field Measurements General Physical Field Measurements

8. Further Breakdown of Measurement/Monitoring Site Safety Monitoring and Screening Detection of Radiation (Ludlum Geiger Counter) Detection of Radiation (Ludlum Geiger Counter) Niton Field XRF Niton Field XRF OMNI-4000 Portable Gas Detector OMNI-4000 Portable Gas Detector Photovac 2020 Photoionization Air Monitor Photovac 2020 Photoionization Air Monitor ToxiRAE Toxic Gas Monitor ToxiRAE Toxic Gas Monitor

9. How We Got Where We Are 1 st - Strongly Encouraged To Be Accredited Evaluated Accrediting Options (Lab and Field; 3 rd Party; Covered By National/International Requirements For Accrediting Bodies (ISO Guide 58)) Evaluated Accrediting Options (Lab and Field; 3 rd Party; Covered By National/International Requirements For Accrediting Bodies (ISO Guide 58)) Once Selected, Measured Where We Were (Gap Analysis) Once Selected, Measured Where We Were (Gap Analysis) Developed/Improved Procedures and Systems Developed/Improved Procedures and Systems Implemented the Accreditation System Implemented the Accreditation System

11. How We Maintain What We Have? Technical Aspects Technical Aspects –Procedures –Equipment –Personnel Training and Testing –Data Package Reviews General Aspects General Aspects

12. How We Maintain What We Have Technical Aspects Procedures Procedures –Implement Review Schedule of Current Procedures (Keep Current) –Continue To Evaluate New Activities

13. How We Maintain What We Have Technical Aspects (con’t.) Equipment Equipment –Calibrate/Maintain/Manage Equipment per SOPs and Instrument Manuals –Track Equipment Management with Equipment Logbooks and an Equipment Database (database not required) –Manage and Track Standards/Reagents Used in Branch Check standards/gases we receive Check standards/gases we receive

15. How We Maintain What We Have Technical Aspects (con’t.) Personnel Training and Testing –Competency Evaluations –Proficiency Testing –Database

16. How We Maintain What We Have Technical Aspects (con’t.) Data Package Reviews Performed for all field analysis presented in reports or used in EPA decisions Performed for all field analysis presented in reports or used in EPA decisions Review documented Review documented Resolution of all issues prior to issuance of data Resolution of all issues prior to issuance of data

17. How We Maintain What We Have General Aspects Document Control Document Control Records Management Records Management Purchasing Purchasing Internal Audits Internal Audits Perform Corrective and Preventative Actions, as Needed Perform Corrective and Preventative Actions, as Needed Evaluate Civil and Criminal Testimony Evaluate Civil and Criminal Testimony NEW – Determine Measurement Uncertainty of Our Field Measurements such as TVA and pH data NEW – Determine Measurement Uncertainty of Our Field Measurements such as TVA and pH data

18.  Confirms Our Commitment to Quality  Better Trained and Capable Employees That Can Demonstrate Their Proficiency  Better Consistency with Application of Sampling and Measurement Techniques How We Feel Accreditation Helps Us

19.  Helps assure legal community/public that NEIC capable of generating reliable and legally defensible data  Demonstrates that NEIC has taken a recognized and systematic approach to planning, conducting, documenting, and assessing our environmental data collection activities (plan, do, check, act….) How We Feel Accreditation Helps Us (con’t.)

20. Advanced/Alternate Concepts for Field Environmental Programs 1) Develop and implement field measurements and sampling competency and proficiency testing program 2) Evaluating and reporting measurement uncertainty for field measurements (and sampling?) 2

21. Competency/Proficiency with Field Measurements/Sampling To qualify staff to perform work To qualify staff to perform work Thoroughly train staff Thoroughly train staff –Review operating procedure/instrument manuals –Demonstrate in simulated situations and On-the- Job Competency evaluated by NEIC subject matter expert(s) Competency evaluated by NEIC subject matter expert(s) Competency evaluation documented and supervisor authorizes to perform specific work Competency evaluation documented and supervisor authorizes to perform specific work

23. Proficiency Testing Annually - internally check staff proficiency - demonstrate ability to perform specific sampling and/or measurements Annually - internally check staff proficiency - demonstrate ability to perform specific sampling and/or measurements Not all – every year Not all – every year Perform limited external PTs for measurements (for areas such as pH, conductivity, total VOCs) Perform limited external PTs for measurements (for areas such as pH, conductivity, total VOCs) Document the testing Document the testing

26. Evaluating and Reporting Measurement Uncertainty for Field Measurements Take data from comp/prof tests (and instrument precision tests required by Regs) or calibration data Take data from comp/prof tests (and instrument precision tests required by Regs) or calibration data Evaluate data to assure results within NEIC’s and instrument’s specifications Evaluate data to assure results within NEIC’s and instrument’s specifications Can sort by instrument, person tested, date, etc. Can sort by instrument, person tested, date, etc. Develop MU statement from this data and/or instrument specs Develop MU statement from this data and/or instrument specs

27. TVA Data Example Used Statgraphics to analyze data from testing and calibration (130 and 620 points) Used Statgraphics to analyze data from testing and calibration (130 and 620 points) Individual TVA results well within that allowed by particular regulation we use instrument for (+/- 10%) and the instrument stated precision (+/- 25%) – we found within 3.7% for testing Individual TVA results well within that allowed by particular regulation we use instrument for (+/- 10%) and the instrument stated precision (+/- 25%) – we found within 3.7% for testing Report MU calculations in our reports (if customer wants) – have in our project records Report MU calculations in our reports (if customer wants) – have in our project records

28. Various Illustrations of TVA Data

29. Measurement Uncertainty TVA Organic Data Summary Statistics Summary Statistics Count = 620 Count = 620 Average = 100.302 Average = 100.302 Median = 100.0 Median = 100.0 Mode = 100.0 Mode = 100.0 Standard deviation = 1.44852 Standard deviation = 1.44852 Minimum = 95.0 Minimum = 95.0 Maximum = 120.0 Maximum = 120.0 Range = 25.0 Range = 25.0 Stnd. skewness = 49.0484 Stnd. skewness = 49.0484 Stnd. kurtosis = 298.958 Stnd. kurtosis = 298.958 Coeff. of variation = 1.44416% Coeff. of variation = 1.44416%

30. Sampling Measurement Uncertainty??? Currently collecting analytical data from our triplicate samples into a database Currently collecting analytical data from our triplicate samples into a database Collect information on sampling methodology, sample media (liquid, solid, gas, etc.), sampling tools used, sampler name, dates, analysis, etc. Collect information on sampling methodology, sample media (liquid, solid, gas, etc.), sampling tools used, sampler name, dates, analysis, etc. Looking for trends in the data, areas for improvement, tentative MU calculations Looking for trends in the data, areas for improvement, tentative MU calculations No MU calculations reported……..yet No MU calculations reported……..yet

31. Other Program Advancement Options EPA’s RS&T Director’s Field Operations Group (FOG) EPA’s RS&T Director’s Field Operations Group (FOG) FOG’s mission….. FOG’s mission….. Adopt five FOG Infrastructure Standards that concern Field Activities Adopt five FOG Infrastructure Standards that concern Field Activities Buy-in from all Regions – applied in Regions 2 and 4 – commitment from Regions 5, 6, 7, 9 Buy-in from all Regions – applied in Regions 2 and 4 – commitment from Regions 5, 6, 7, 9 3

32. 5 FOG Infrastructure Standards – Relate to…. Evidence Management Evidence Management Document Control Document Control Records Management Records Management Personnel Training and Records of Training Personnel Training and Records of Training Equipment and Instrument Inventory Equipment and Instrument Inventory

33. Another Option Adopt and/or seek eventual certification through TNI (The NELAC Institute) of field measurements and sampling Adopt and/or seek eventual certification through TNI (The NELAC Institute) of field measurements and sampling –Primarily for environmental govt. and other organization’s labs but writing some standards for field activities now –Have Drafted “General Requirements For Field Sampling and Measurement Organizations” Document (2007)

34. Many options to go down the road of continuous improvement Contact me w/ any questions about the Field Ops Group 5 infrastructure standards, becoming ISO accredited, or any other topic discussion items in this presentation! Kenna Yarbrough, Field Branch QA Representative/Inspector USEPA/NEIC, Denver, CO (303) 462-9256 yarbrough.kenna@epa.gov